Why You Need to Know Emily Parker

WHY YOU NEED TO KNOW HER

Because she hasush-ered some of the biggest names in oil and gas through some of the toughest precedent-setting tax litigation cases in history. After joining Thompson & Knight LLP as its first female lawyer in 1973 fresh out of SMU’s Dedman School of Law, Parker spent the first 28 years of her career learning the ropes of tax law and ascending through the ranks to become the firm’s first female partner. These days, with more than four decades of experience under her belt, the Henderson, Texas, native is one of the top tax litigators in the country.

“I didn’t come into the practice of law with undying ambition, or any real understanding of what a tax lawyer might do in a large firm,” Parker says. Instead, she credits a suggestion from a mentor as the inspiration behind her decision to practice tax law. She fondly remembers when former Thompson & Knight Partner J. Waddy Bullion approached her after the firm lost another young tax lawyer. Parker had just written a tax memo at the behest of Bullion, and she remembers he’d been pleased with her work.

“My momma didn’t raise a fool, so I said, ‘Yes sir, Mr. Bullion, I’ve always wanted to be a tax lawyer,’” Parker says. “I’d had tax courses in law school, and I had found them intellectually interesting. It’s like the tax law is this very difficult jigsaw puzzle.”

“If I could predict the price of oil … I’d be on my own private island.” — Emily Parker

In many cases, Parker has figured out how to solve that puzzle. In one of her first victories, she prevailed on behalf of Texas Instruments in designating the geophysical and seismic data it collected as “tangible property,” meaning that TI could claim investment tax credit against costs associated with obtaining that data. Though it didn’t directly involve the oil and gas industry, this case set the stage for a number of Parker-led precedent-setters that affected big-name clients like Texaco, Gulf Oil Corp., Chevron, and Sunoco.

“For the petroleum industry itself, some of the most interesting cases I worked on involved the tax treatment of the cost of developing offshore properties, like in the Gulf or the North Sea,” Parker says. “I think the very first memo I can remember writing as a lawyer was about a tax issue for a major oil company—Texaco, a company I did work for throughout my career.”

And she has had quite the career, peppered with historical price dips and surges and fierce geopolitical tension. Parker saw the price of oil spike to more than $40 a barrel in the late ’70s and early ’80s, and then drop to just $8.50 in the late ’80s before it recovered again in the early 2000s. She can trace these spikes back to various geopolitical events—the Iranian Revolution and subsequent eviction of U.S. oil companies, the seizure of Mecca’s Grand Mosque by the House of Saud, the Iran-Iraq War—and her international savvy and quickness to recall the historical facts have proved to be crucial in the courtroom.

“The reason I know this so clearly is that I handled a case for Texaco about the transfer price of Saudi crude over the period of ’79 to ’81,” Parker explains. She would go on to usher Texaco through Chapter 11 bankruptcy in 1987 after an $11 billion spat with Pennzoil, which she calls a significant point in history for the Aramco shareholders Texaco, Chevron, Exxon, and Mobil. Her boots-on-the-ground experience on high-profile cases with worldwide implications also made her an attractive hire for the U.S. government, which lured her to work for the Internal Revenue Service in Washington, D.C., in 2002.

While on Capitol Hill serving as deputy chief counsel in the largest counsel office in the federal government (with around 1,600 other attorneys), Parker was responsible for all litigation, advice to the IRS, and some writing of rulings and regulations pertaining to internal revenue code. In the months following 9/11, Parker treated her government job with a sense of patriotic responsibility, despite having battled the IRS previous cases.

And when the IRS acting chief counsel resigned in 2003, Parker took the helm. In this role, she was responsible for all operations of the Office of Chief Counsel, including litigation, advice to the IRS, and all rulings and regulations as the chief legal advisor to the IRS Commissioner.

She made her way back to Dallas in 2004—and back to tax law and Thompson & Knight. She’s often recruited to weigh in and bring analysis and historical context to various discussions relating to the petroleum business, price volatility, and the future of the industry. All experiences considered, Parker, who became the first woman to be elected managing partner of Thompson & Knight in 2012, says she’s no soothsayer.

“If I could predict the price of oil, I wouldn’t be here; I would be on my own private island,” Parker says with a lighthearted smile. “I’m a lawyer, and my perspective on the industry comes from a different viewpoint. What I’m seeing is that, despite current oil prices, huge amounts of money are still flowing into the oil and gas industry today.”